E-Filing Expense Part of Decision Very Instructive.
Ya know, some cases are so fact and procedurally specific that we have to pull back from giving all the specifics. Sheldon v. Strong, Case No. G048770 (4th Dist., Div. 3 Sept. 22, 2014) (unpublished) is just such a situation, but there are two good takeaways from this one.
First one is that a litigant’s dismissal of a case, even without prejudice, likely disenfranchises an assignee’s interest in a cost award.
The second one concerns whether mandatory electronic filing fees in superior court actions are recoverable as routine costs. This opinion says they are, given that the pilot project is mandatory and litigants have no choice but to comply with the filing requirements. They certainly qualify as routine costs, especially given their mandatory character.
Acting Justice Rylaarsdam authored the opinion on behalf of a 3-0 panel.